Justia Wyoming Supreme Court Opinion Summaries

Elijah Dante Dobbins was convicted by a jury of third-degree sexual abuse of a minor, strangulation of a household member, unlawful contact, and permitting a house party. The incident occurred during a party at Dobbins's apartment, where a physical altercation between Dobbins and his girlfriend, Harmony Lehmbeck, was recorded by a coworker. The videos showed various stages of the struggle, including moments where Dobbins appeared to choke Lehmbeck. Lehmbeck testified that Dobbins did not choke her and that she did not lose consciousness.The District Court of Natrona County admitted the videos as evidence during the trial. After the case was submitted to the jury, the court clarified which exhibits were admitted and stated that the videos would not be sent to the jury room but could be reviewed in the courtroom if requested. During deliberations, the jury asked to view the videos to clarify the alleged strangulation and battery. The court, with the approval of both parties, allowed the jury to view the videos twice under supervision.The Wyoming Supreme Court reviewed the case and affirmed the district court's decision. The court held that the videos were non-testimonial, meaning the district court had broad discretion to allow the jury to review them during deliberations. The court found that the district court did not abuse its discretion by permitting the jury to view the videos again, given their short duration and the need for clarity on the strangulation charge. The court concluded that the district court's controlled procedure for reviewing the videos was appropriate and did not unduly emphasize the evidence. View "Dobbins v. State" on Justia Law

The State of Wyoming owns a 3.37-acre parcel in Uinta County, leased to Pilot Corporation for operating a truck stop. The property, held for the benefit of the Wyoming State Hospital, generates revenue for the hospital through the lease. In 2022, the Uinta County Assessor assessed the property for taxation, which the State contested, claiming the property was used primarily for a governmental purpose and thus exempt from taxation.The County Board of Equalization initially ruled in favor of the State, stating the property was used for a governmental purpose because the Board of Land Commissioners had a fiduciary duty to generate revenue for the hospital. However, the State Board of Equalization reversed this decision, holding that the Department of Revenue’s rules, which state that governmental property used by a lessee for non-governmental purposes is not tax-exempt, were binding. The district court affirmed the State Board’s decision, agreeing that the lessee’s use of the property for a truck stop did not constitute a governmental purpose.The Wyoming Supreme Court reviewed the case and affirmed the district court’s ruling. The Court held that the property was not exempt from taxation because it was used by the lessee, Pilot Corporation, for a non-governmental purpose. The Court emphasized that the end use of the property by the lessee determines its tax status, not the purpose of the lease. Additionally, the Court found that the legislature had not provided an exemption for such properties, as required by the Wyoming Constitution. Therefore, the property was subject to taxation. View "State of Wyoming v. Uinta County Assessor" on Justia Law

Phoenix Capital Group Holdings, LLC (Phoenix Capital) sought to recover mineral royalties as a life tenant and alternatively to reform the deed that established its life estate. The dispute arose from a series of property transfers beginning in 1977, when Mr. and Mrs. Peterson transferred a parcel of real property to Alva and Velma Woods, retaining a life estate in the mineral estate. In 2003, Alva and Velma deeded the property to their son Paul and his wife Cheryl, intending to retain a life estate in the mineral estate. However, the 2003 deed did not reserve this life estate, leading to a 2006 deed that conveyed a life estate in one-half of the mineral estate to Alva and Velma. Subsequent leases were executed, and in 2021, Velma sold her life estate to Phoenix Capital.The District Court of Laramie County dismissed Phoenix Capital’s claims. It concluded that under the doctrine of waste, a life tenant does not have the right to receive royalties unless expressly stated in the deed or agreed upon with the remainderman. The court also found that the claim to reform the deed was barred by the statute of limitations, which began when the deed was recorded in 2006.The Wyoming Supreme Court reviewed the case and affirmed the lower court’s decisions. The court held that the doctrine of waste precludes a life tenant from receiving royalties without an agreement with the remainderman or express language in the deed. The court also held that the statute of limitations for reformation claims begins when the deed is recorded, making Phoenix Capital’s 2022 reformation claim untimely. The court found no error in the district court’s application of settled law and affirmed the dismissal of Phoenix Capital’s claims. View "Phoenix Capital Group Holdings, LLC v. Woods" on Justia Law

A police officer responded to a hotel where a mother, RN, was intoxicated and with her six-year-old son, JN. Due to her intoxication and the presence of a violent boyfriend at home, JN was taken into protective custody. RN tested positive for amphetamines and had a high blood alcohol content. The State filed a neglect petition, and JN was placed in foster care. The initial permanency plan was family reunification, and RN was required to follow a case plan that included maintaining sobriety and addressing her relationship with her boyfriend.The juvenile court held a shelter care hearing and placed JN in the State's temporary custody. RN made some progress but failed to maintain sobriety and continued her relationship with her boyfriend. The court extended the consent decree to allow more time for RN to comply with the case plan. However, RN missed drug tests, tested positive for methamphetamine, and failed to appear at a hearing, leading to the revocation of the consent decree and the adjudication of neglect. The permanency plan was updated to require inpatient drug treatment, but RN did not check into treatment until the day before the permanency hearing.The Wyoming Supreme Court previously reversed the juvenile court's order changing the permanency plan to adoption due to the lack of a reasonable efforts determination by the Department of Family Services (DFS). On remand, the juvenile court determined that DFS had made reasonable efforts based on the evidence from the original hearing and reaffirmed the change in the permanency plan. The court found that despite RN's bond with JN, her inability to maintain sobriety and provide a stable environment justified the change to adoption. The Wyoming Supreme Court affirmed the juvenile court's decision, finding sufficient evidence that the change was in JN's best interests. View "RN v. The State of Wyoming" on Justia Law

A group of property owners and entities challenged the Albany County Board of County Commissioners' amendments to zoning regulations known as the Aquifer Protection Overlay Zone (APOZ). The amendments aimed to protect the Casper Aquifer, which supplies drinking water to many residents in Albany County, including those in the City of Laramie. The property owners argued that the Board's adoption of the amendments was arbitrary, capricious, and exceeded its authority.The District Court of Albany County dismissed the petitions for review, concluding that it lacked jurisdiction because the amendments were legislative acts and not reviewable under the Wyoming Administrative Procedure Act (WAPA). The property owners and entities appealed, arguing that the Board's actions were reviewable and that the Board lacked the authority to adopt the amendments.The Wyoming Supreme Court reviewed the case and clarified that there is no common law or general statutory exception to judicial review of agency legislative actions. The court held that the characterization of the Board’s action as legislative or adjudicatory dictates the scope and nature of the review. The court concluded that the district court has jurisdiction to review the APOZ amendments and remanded the case to the district court to conduct an analysis in conformance with the opinion. The court emphasized that judicial review of agency legislative actions is limited by the separation of powers doctrine and should focus on whether the actions were contrary to constitutional rights, not in accordance with the law, in excess of statutory authority, or divergent from the agency's own rules. View "Warren Livestock, LLC v. Board of County Commissions" on Justia Law

William R. Durkin, III, pled guilty to felony theft and felony property destruction and was sentenced to concurrent terms of five to eight years in prison, which were suspended in favor of a split sentence of one year in county jail followed by four to five years of supervised probation. After moving to Michigan, Durkin violated his probation by using alcohol and cocaine. As a sanction, Michigan Probation required him to complete the Tri County Community Adjudication Program (TRICAP), a probation residential center. Durkin spent 107 days at TRICAP but later violated probation again by drinking alcohol and absconding. Wyoming authorities filed a motion to revoke his probation, and Durkin was arrested in 2023.The District Court of Converse County revoked Durkin's probation and imposed his suspended prison sentences, reducing them to concurrent terms of four to six years. The court credited him for 413 days served in official detention in Wyoming but denied credit for the 107 days spent at TRICAP. Durkin appealed the revocation order and filed a motion to correct his sentences, arguing that the court erred by not crediting his time at TRICAP. The district court denied his motion, and Durkin appealed this decision as well.The Supreme Court of Wyoming reviewed the case and affirmed the district court's decision. The court held that Durkin was not in "official detention" while at TRICAP, as it was not an approved Wyoming Adult Community Corrections (ACC) program and did not subject him to escape charges under Wyoming law. Consequently, Durkin was not entitled to credit against his prison sentences for the time spent at TRICAP. The court concluded that the district court's sentences were legal and properly denied Durkin's motion to correct his sentences. View "Durkin v. The State of Wyoming" on Justia Law

In the early morning of July 8, 2022, Officer Luke Thorp of the Mills Police Department responded to a report of an unconscious male in a truck with syringes on the ground nearby. Upon arrival, Officer Thorp found Travis Dean Schaub in the vehicle, appearing disoriented and exhibiting signs of intoxication. After a slow and difficult exit from the vehicle, Schaub refused consent to a search, but Officer Thorp proceeded to search him, finding methamphetamine. Schaub was then handcuffed, placed in the patrol vehicle, and read his Miranda rights.The District Court of Natrona County reviewed Schaub’s motion to suppress the evidence obtained during the search, arguing it exceeded the scope of an investigatory stop and lacked a warrant. The State contended that the search was justified as incident to a lawful arrest for public intoxication. The district court agreed with the State, finding that Officer Thorp had probable cause to arrest Schaub for public intoxication under the Mills Municipal Code, and thus the search was lawful.The Supreme Court of Wyoming reviewed the case and affirmed the district court’s decision. The court held that Officer Thorp had probable cause to arrest Schaub based on his observed intoxication and the presence of syringes. The court further held that the search was valid as incident to a lawful arrest, even though it preceded the formal arrest by a few minutes. The court emphasized that the Fourth Amendment does not require the arrest to precede the search, as long as the arrest follows quickly and there is probable cause. Therefore, the denial of Schaub’s motion to suppress was upheld. View "Schaub v. The State of Wyoming" on Justia Law

On January 12, 2023, Officer Kevin Valentine of the Buffalo Police Department responded to a report of a suspicious vehicle at a gas station. The vehicle, a white Toyota Camry with Montana plates, had been parked at a pump for 30-45 minutes with its windows covered. Upon arrival, Officer Valentine observed Robert Labbe exiting the vehicle and asked him to return to the car for questioning. Labbe did not have his driver’s license, and a check revealed his license was suspended. The passenger, Elizabeth Davison, also had a suspended license and an active warrant.Officer Dustin Matthews arrived to assist, and after arresting Davison, the officers requested a canine unit. Deputy Quinn Maddox and his drug detection dog, Lucy, arrived 18 minutes later. Lucy alerted to the presence of drugs, leading to a search that uncovered marijuana, paraphernalia, and suspected fentanyl pills. The vehicle was towed for a more thorough search, revealing significant quantities of methamphetamine, fentanyl pills, marijuana, and THC. Labbe was charged with multiple counts of possession of controlled substances.Labbe filed a motion to suppress the evidence, arguing the drugs were found as a result of an illegal detention. The District Court of Johnson County denied the motion, stating the vehicle was in a public parking lot and law enforcement did not need reasonable suspicion, probable cause, or consent for a canine sniff. Labbe entered conditional guilty pleas to two felony counts, reserving the right to appeal the suppression ruling.The Wyoming Supreme Court affirmed the district court’s decision. The court held that the canine sniff was lawful as it occurred in a public place, and the dog’s alert provided probable cause for the search. The court found the evidence was not obtained as a result of an unlawful detention, making the search and subsequent seizure of drugs lawful. View "Labbe v. The State of Wyoming" on Justia Law

Kerry and Jeanie Cooper entered into a five-year lease agreement with James and Melisa Crouch to lease farmland for pasturing cattle and growing crops. The lease was set to expire in February 2022, but the Crouches terminated it early, citing the Coopers' failure to employ standard best management practices. The Coopers filed a lawsuit for breach of contract, claiming they were not given adequate notice or an opportunity to cure any alleged default as required by the lease.The District Court of Fremont County found that the Crouches breached the lease by failing to provide the required notice and opportunity to cure. The court awarded the Coopers $153,772.05 in damages, which included costs for feed, supplements, trucking, and replacement pasture. The court also reduced the damages by $24,650.35 for the Coopers' failure to mitigate damages by selling leftover hay.The Supreme Court of Wyoming reviewed the case and affirmed the district court's findings. The court held that the Crouches did not provide the Coopers with a meaningful opportunity to cure the alleged default, as the termination letter did not specify how to remedy the issues. The court also rejected the Crouches' first-to-breach defense, stating that they could not rely on the Coopers' alleged breach to excuse their own failure to provide proper notice.However, the Supreme Court found that the district court had erroneously included the costs of the pasture leases twice in its damages calculation. The court remanded the case with instructions to reduce the damages award by $2,660.60, affirming the decision in all other respects. View "Crouch v. Cooper" on Justia Law

On March 4, 2023, Officer Brandon LaPointe stopped Antonio Kaye Lee's vehicle for illegally tinted windows. After confirming the tint violation, Officer LaPointe called for a canine unit, which alerted to narcotics. A search revealed methamphetamine and drug paraphernalia. When informed of his arrest, Mr. Lee resisted, leading to a struggle during which officers claimed he attempted to grab their firearms. Mr. Lee was charged with multiple offenses, including two counts of attempting to disarm a peace officer.The District Court of Sweetwater County presided over the trial. Mr. Lee admitted to the drug-related charges but denied attempting to disarm the officers, asserting he was merely trying to escape. The officers testified that Mr. Lee grabbed their firearms during the struggle. The jury found Mr. Lee guilty on all counts, and he was sentenced to concurrent prison terms for the misdemeanors and the attempted disarming charges.The Wyoming Supreme Court reviewed the case, focusing on whether the district court erred by not instructing the jury on all elements of attempting to disarm a peace officer, specifically the requirement of a "substantial step" toward committing the crime. The court found that the district court's failure to include this element in the jury instructions constituted plain error. The Supreme Court held that this omission materially prejudiced Mr. Lee because the jury might not have found he took a substantial step toward disarming the officers, given the conflicting testimonies. Consequently, the Wyoming Supreme Court reversed the district court's decision. View "Lee v. The State of Wyoming" on Justia Law